Ben Chang - No way. He was an ass who enjoyed being antagonistic towards people From what I can remember, he never did anything villainous and is much more well known as being a douchebag teacher or douchebag student or douchebag campus-police than he is a villain.
Bulk & Skull - Same as above.
Seto Kaiba - Just an anti-hero. Apparently he was a villain in Season Zero, but everyone knows and loves Kaiba as the overdramatic d*** who screws the rules. Not as some villain with green hair.
Ty Lee - She is a nice person who got forced into doing bad things for Azula. It's a crap reason I admit, but I just don't see her as a villain.
Uchiha Itachi (Naruto) - Shoved down our throats far too much as a protagonist for him to have been an antagonist.
Uncle Iroh - I don't see how anyone can think of him as a villain >_>
Willie Stokes (Bad Santa) - I'd say no. The elf was the villain of bad santa.
*TWEWY and Higurashi spoilers*
I know technically they count, but Joshua and Takano are d*** nominations >_>. Huge spoilers for both series just by looking at their names on the list. There's probably some more like that on the list, but they're the two that sprung to mind. At least consider changing Joshua's name to The Composer >_>
*End Spoilers*
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if a tree falls in the forest and no one is around to hear it do the other trees laugh?